Reflections on the Sexual Abuse of Minors by Priests

Dr. Aaron Milavec, Catherine of Siena Virtual College

Some people have gained the impression that sexual abuse of minors by priests is a very recent phenomenon. Those who are in the know, however, realize that sexual improprieties have been going on quietly for a long time and that, only in recent times, have they come into the public limelight. The statistics for the United States are staggering:

The United States Conference of Catholic Bishops (USCCB) [official website] reports having received allegations from 14,000 victims against 5,600 priests between 1950- 2008. The official numbers are found in the 2004 John Jay Report [text] commissioned by the USCCB and the subsequent implementation report [text, PDF] from 2008. Estimates [BishopAccountability.org report] of the total number of US children who were abused since 1950 range from 25,000 to close to 300,000.®

My personal reflections on this worldwide ecclesiastic crisis are divided into two parts: (a) Cultural factors shaping the current crisis and (b) Ecclesiastical factors aiding and inhibiting the bishops' response.

Cultural Factors Shaping the Current Crisis

Cultural factors play a large role in accounting for why the pedophilia crisis has emerged into the public limelight.

To begin with, one has to reflect on how tolerance for sexual abuse within families has markedly decreased in our own lifetime. A man used to be able to beat his wife with impunity and to terrorize and sexually abuse his children as well without any outside interference of any kind. The victims were ashamed to tell even members of their wider family. They were oftentimes persuaded that they brought these things upon themselves and somehow deserved their mistreatment. Fear clouded their minds and they were cowered into silent submission.

A daughter who complained to her own mother after months of escalating sexual foundling by their father was often accused of "making up stories" or of "giving themselves over to exaggeration." Some daughters were even advised that sexual submission was "the small price" that a woman had to learn to willingly pay in order to gain and retain the protection and

support of a man and that it was "not such a bad thing for your father to prepare you to submit your body to your future husband/'

Wives and children, of course, could always run away but, without a powerful protector, such women and children would be inevitably preyed upon by even more hard-hearted predators who knew the art of how to enslave them sexually and to exploit them for personal gain. The aberrations that take place today in war zones, in refugee camps, in harrowing slums, in secret prisons, and even in the Astrodome of New Orleans following the hurricane Katrina are just the reality check that demonstrates how sexual exploitation of the weak is a cultivated habit that infects a small portion of every society, esp. when patriarchy and misogyny hold sway.

Why do children permit themselves to be sexually abused? The truth is that generally they are not even aware that they are being "abused" and that this abuse is "sexual." This only comes many, many years later.

Case One: Susan, a cute neighborhood girl of ten, came over to plant flowers with me. As we plant together, she tells me, with a sense of pride, that she has "a very special relationship" with her dad. I respond, "Oh, that's nice, tell me about it." "Oh, I wish I could, but I can't. My dad made me to promise never to tell anyone. I can't even tell my sister or my mother." "Why can't you tell me." "My dad said it would get him in trouble, and a policeman would put him in jail."

As I heard these things, red flags went up. "Special relationship" could be the kind of talk her father (a lawyer estranged from his wife) might use by way of sugar-coating his inappropriate touches. The emphasis on secrecy and the threat of disclosure were also suspect. Overall, however, Susan feels very special to be included in her father's night-time rituals!

Case Two: Albert Green vividly remembers the first time he saw the home of the Rev. Ed Olszewski, the priest who cared for him [as an orphan] when he was 11. "The first day, I was so excited. I went running through the church. Everything was so pretty -- it was like a mansion. It had twelve bedrooms and six bathrooms. It was humongous," said Green [recalling these early events for the jury]. Green remembers the mysterious chute that dropped dirty clothes right down to the laundry room, the giant bowl filled with silver dollars and the cool stuff in the priest's bedroom: a little fridge with soft drinks in it, a popcorn machine, the soft rug in front of his bed.

He also remembers that Olszewski didn't wait long to establish that their relationship would be sexual. Green said that [on their] first night, they went to Olszewski's bedroom and drank some wine. Then Olszewski took out some Vaseline and "he was rubbing it on me, on my front and my back. He put it up into my rectum. I felt something really weird. I just turned over and felt something else go inside of it." While the priest had sex with him, Green said, he was looking

over at the bowl full of shiny coins, thinking "all this money. He's going to give it to me," Green said.

Green said he also liked the power and stature that came with being the priest's surrogate son: "I knew what he was doing. I just felt like he was my father, he was the president, whatever he says, goes. I never really had nothing, now I'm rich and famous. ... I felt special," he said, ( www)

The parallels between Green and Susan are striking. Both children were hungry to be nurtured, protected, and made to feel "very special." The sexual contact was a small price to pay for this.

In the 2004 play and 2009 movie, "Doubt," the mother of the only African-American student in a parochial school is confronted with the principal's suspicion that the priest, Fr. Flynn, has entered into a sexual relationship with her son. In response, the mother, Mrs. Muller, stands her ground against the principal. She explains that her son needs a sympathetic father figure and a protector in a hostile school environment wherein racial teasing runs high. She says to the principal something like this: "It makes no difference to me whether Fr. Flynn is guilty or innocent. What I see is that my son has grown in self-confidence, that he is no longer ridiculed by the white boys, and that he is set on a course toward achieving his goals. All of these changes have taken place after Fr. Flynn has taken him under his wing. If my son happens to be in that way [homosexual], then it is a small price to have him initiated by a caring priest." Sr. Aloysius interpreted this response as crass and uncaring. She secretly hoped to shock Mrs. Muller into withdrawing her son from the school. Yet, to her credit, the mother engaged in a moral reasoning that took into account the whole range of effects that Fr. Flynn's patronage had upon her son.

Other cultural factors also come into play. As the tolerance for sexual abuse has been radically declining, the tolerance for "sex tourism" has been massively expanding in various Asiatic countries and the American military continues to offer combat troops R&R ["rest and relaxation"] in the Philippine brothels surrounding American bases. In such a world where utilitarian values hold sway, one should not be surprised that reputable scholars publish books and Christian "experts" sponsoring websites that openly advocate the advantages of pedophilia:

Pedophiles who decide to act out are usually someone who the child loves and respects. The experience (before society dumps its guilt and other garbage) is usually positive. The sex is mutual and pleasurable in many cases to both parties, especially when the relationship is a good, loving one. . . . Allow children fredom [sic] of choice! Promote RELATIONSHIPS between youngsters and adults!

What these sites fail to recognize is that "consent" on the part of children is often overwhelmed by the "initiative" on the part of male adults who cleverly exploit their "innocence" and "trust" and "longing for human contact." Furthermore, patriarchy offers men a sense of entitlement. Their sexual satisfaction is morally legitimated even when it is achieved at the expense of the women and children involved. The claim that "the sex is mutual and pleasurable" never takes into account the imbalance of power that exists in pedophilia (as well as in sex tourism and R&R). Furthermore, in the case of children, there is a glaring imbalance of sexual power due to the as-yet-undeveloped sexuality of children. Thus, there must always be a degree of male exploitation present even in those instances where the child finds the encounter satisfying. Recall Green saying, "I never really had nothing, now I'm rich and famous." Young women offering sex tourism and R&R might even be able to say much the same thing. When examined more closely, this is all a seductive fiction brewed in the fragile imaginations of men feeding on their sense of "male entitlement." Priests, truth to say, have no special immunity to "male entitlement."

Ecclesiastical Factors Aiding and Inhibiting the Bishops" Response Prior to 2002, the response of the U.S. Catholic bishops was overwhelmingly in favor of silencing victims and preventing public scandal. After 2002, these same bishops turned things around and drew up a "Charter" with the Catholic people to put into place protections at all levels and, above all things, to stand by the children who had been abused.

In the early period, from Vatican II to 1980, most bishops listened to the complaints of parents and guardians and then followed through by confronting accused priests in private. Some boldly refused to allow that there was any substance to the rumors that had been brought against them. Others confessed their misconduct and poured out tears of repentance that sufficed to convince their bishops that they had turned from sin to grace. After a time of prayer and reflection, these priests were generally assigned to new pastoral locations where they could make a clean start.

When psychological testing was first introduced in the 1980s as the preferred way to weed out unfit candidates applying to the seminary, stress was placed upon psychological assessments by way of assuring bishops that those entering the seminary had a adult psychological profile and were capable of undertaking a life of committed celibacy. During this period, bishops also asked the advice of trusted psychologists respecting wayward priests addicted to drink or to sex or to drugs. On the basis of the best advice of professional psychologists, they began to realize that mere contrition and the firm resolve not to sin again was largely ineffective when it came to addictive behaviors. They thus began to send troubled priests to isolated psychological centers wherein they could recover their spiritual and psychological health. When deemed

"cured/' such priests could be reassigned to a parish in a new geographical center where they could have a "fresh start" free of the lingering rumors and the human mess that they had created in their former pastoral settings.

Meanwhile, in the 1980s, an avalanche of fresh accusations surfaced. No one knows how many cases were reported since the bishops routinely followed the policy of protecting the reputations of the perpetrators and of doing damage control within the community. Reported cases of child sexual abuse across the United States reached epidemic proportions from 1980 to 1990, with a reported 322 percent increase from 1980 to 1990. Given the logic shared earlier, one can suspect that the bishops received an epidemic rise in reported incidents of sexual abuse by priests also during this period.

At this point, no bishop within the United States was handing over evidence to the local police regarding the confirmed sexual improprieties of their priests. Their logic was that this was an internal affair, and that their responsibility ended when a priest had taken up residence in an addiction center and his case file, complete with the sworn testimony of witnesses pledged to secrecy, was transferred to the Congregation for the Doctrine of the Faith in Rome, which was under the direction of Cardinal Ratzinger from 1981 to 2005.

The old adage was that "Rome moves slowly" and, in the affair of wayward priests, this applied in full rigor. The notion that a tribunal of complete strangers in the Vatican could competently decide the juridical future of the accused on the basis of sworn testimony (wherein the accused never had to face his accusers; and, in many instances, was never even permitted to know the identity of his accusers and wherein no cross-examination of live witnesses was possible) may seem ludicrous to us today, but bishops were subservient to whatever the Vatican decided and were perhaps relieved that they could obediently hide behind the decision of a Vatican tribunal when the hard judgments were finally passed down. But the greatest failure of the Vatican system is that neither the accused nor the accusers are present at the deliberations. Even the judges were sworn to secrecy and could never discuss the cases they decided with either the victims or the perpetrators. Such a system is thoroughly unsatisfactory since neither the victims nor the perpetrators have any way of knowing whether their case received a "fair hearing." Moveover, there was no public scrutiny that would allow anyone to evaluate the reliability of the proceedings or for experts to make recommendations for improving them.

 

In the patristic churches of the second to the fifth century, local bishops with a Roman province met twice yearly for the purpose of devising a uniform pastoral plan for the faithful. At these assemblies, any person of any rank could bring forward accusations against any of the assembled bishops. Testimony under oath was received with the accused present and cross examinations were permitted to get at the truth of the affair. Any bishop judged to have acted improperly was disciplined immediately: Some were suspended from their office for a limited time. Others were permanently defrocked. In severe cases, bishops were excommunicated entirely and expected to become penitents living on bread and water, and kneeling at the doors of the church every Sunday beseeching the faithful to pray for them as they entered to celebrate the Eucharist. In this setting, no one ever imagined that disciplining misbehaving bishops was an affair that had to be handled in Rome or that the office of bishop was somehow unaccountable to the local church.

In parallel fashion, in every urban church, the bishop(s) met with his council of presbyters early in the week and routinely heard cases of Christians who were vexed or injured by the conduct of their brothers or sisters in Christ. Christians were asked not to bring their brothers or sisters before the judgment of secular magistrates. After 313, Constantine even allowed that Christians could settle their complaints in these effective church courts and that bishops could wear the stole which, in this era, was the public mark of an official judge. This is why the stole is worn by the priest in the confessional today.

In this era, bishops and presbyters usually resided in their local communities for the whole of their lives. They were well known to everyone in the community. A bishop was chosen on the basis of open deliberation and voting within the council of presbyters. Such appointments were then brought before the entire community and the consent of the entire parish was required before anyone took office. Any presbyter accused of misbehaving was judged by the council of presbyters. Witnesses were sworn in and the accused was invited to speak in his own defense and to call witnesses from within the community." Here, again, no one ever imagined that disciplining misbehaving presbyters (priests) was an affair that had to be handled in Rome or that the office of presbyter was somehow not accountable immediately and directly within the local church.

This diversion into church history is offered here by way of indicating how dysfunctional the Church of the 1980s had become. Some say that the sexual abuse crisis was precipitated by the policy of secrecy and damage control perpetuated by bishops and clergy alike. From my perspective, the problem goes much deeper. Centralization of the Church in Rome (which began as the much needed Gregorian reform o f the 12 th century) left Catholics with an antiquated system of justice that provided scant relief for either the accused or the abused.

Secrecy, moreover, fostered the suspicion that bishop protected their favorites. Bishops were perceived as minimizing the crime, shielding the abusers, and distancing themselves from their victims. Parents often just wanted to receive a fair hearing, an admission of guilt from the perpetrator, and some guarantee that the perpetrator would never again be in a position to create yet more victims. Prior to 2002, these things were in short supply. Secrecy was badly used and abused and misunderstood during this period. Rev. Thomas Doyle, a frequent consultant in both civil and ecclesiastical suits involving clerical sexual abuse, makes this point as follows:

According to the 1922 and 1962 [Vatican] documents, accusers and witnesses are bound by the secrecy obligation during and after the process but certainly not prior to the initiation of the process. There is no basis to assume that the Holy See officially envisioned this process to be a substitute for any secular legal process, criminal or civil. It is also incorrect to assume, as some have unfortunately done, that these two Vatican documents are proof of a conspiracy to hide sexually abusive priests or to prevent the disclosure of sexual crimes committed by clerics to secular authorities. 111

Shortcomings of the Penetential System

Even the practice of sacramental confession left the victims out in the cold. A priest who molested children could screw up his courage and confess his sins to another priest (maybe even his bishop). As a result, the penitent's tears were blessed with the assurance that God had forgiven all their terrible sins and that he could begin with a fresh slate. It never occurred to most confessors to imagine that the "innocence" of a child had been stolen and, as in cases of theft, restitution (according to the means of the person involved) was required before absolution could be given.

The forgiveness in the confessional also deprives angry parents from ever hearing any admission of guilt on the part of the perpetrator. The confessor and God had heard the confession of guilt, but those who were hurt and angry were greeted with only a stony silence. Knowing the history of the development of sacramental confession in the early medieval period would have prompted pastors to practice a "tough love" in the form of a assigning a penance that would have provided some remedy for the immense damage that had been done. Reciting six Our Fathers is hardly a suitable penance for child abuse. More effective would be a full confession of guilt before the child and his extended family. In some cases, an additional public confession before the entire church community would be required along with putting in place credible safeguards that would prevent the priest from having any private encounters with young people ever again. In more grievous cases, the offending priest could be required to also confess his crimes before a magistrate and to serve any civil or criminal penalties. Unfortunately, however, the Catholic penitential system has been so privatized, sanitized, and gutless that little or no remedy for the social effects of sin was forthcoming.

 

It was at this point that the mothers and some fathers of victims got very angry and took charge of their right to protect their daughters and sons from priests who were wolves in sheep's clothing. One such mother explained how her son had been abused as an altar boy and how the priest responsible continued to have monthly sleepovers at the rectory. When she met with the bishop and explained in great detail the confusion and fear of her son after these serial; sexual encounters, the bishop suddenly stood up, put on his stole, and gave her absolution. Then he explained that everything that she said was under the seal of confession and that she had the sacred duty not to reveal to anyone what she had just confessed to him. She was now doubly angry by the bishop's "pious trickery." She stormed out and immediately found a lawyer to bring criminal charges against the priest for "improper sexual conduct with a minor." Later this was expanded to charges against the bishop himself for "knowingly aiding and abetting" the perpetrator's criminal conduct. The court sentenced the priest to three years of imprisonment and the diocese was required to pay $100,000 of punitive damages to the child.

Once frustrated parents caught on to the fact that bishops were reassigning offending priests to new parishes and that most priests so assigned became repeat offenders, more and more parents began to use the legal system to bring forward the remedy that the Vatican system of justice and the confessional were unable to deliver. "Since 2007, in the US alone, the Church has settled more than 500 cases [JURIST news archive] of abuse for over $900 million." This has severely depleted the coffers of just about every diocese in the United States. Properties have been sold. Loans have been taken out. ( www ) In some cases, entire dioceses have had to declare bankruptcy.

It is to the credit of the US Bishops that, in 2002, they did a deep and soul-searching assessment of their delinquency in handling sex-abuse cases. The wake-up call was undoubtedly due to parents and survivors coming forward to tell their stories and to mount legal action against those responsible. They did an about face by turning their full attention to the victims where it should have been all along. Leading experts in all relevant fields were consulted. For the first time, bishops say the necessity for pastoral action in favor of the victims as being the primary and continued response in all case of child abuse.

The bishops' website provides the following summary of the Charter:

The Charter for the Protection of Children and Young People is a comprehensive set of procedures established by the USCCB in June 2002 for addressing allegations of sexual abuse of minors by Catholic clergy. The Charter also includes guidelines for reconciliation, healing, accountability, and prevention of future acts of abuse.

The Charter directs action in all the following matters:

• Creating a safe environment for children and young people;

• Healing and reconciliation of victims and survivors;

•         Making prompt and effective response to allegations;

•         Cooperating with civil authorities;

•         Disciplining offenders;

•         Providing for means of accountability for the future to ensure the problem continues to be effectively dealt with through a national Secretariat of Child and Youth Protection and a National Review Board.

The bishops' website provides further guidance for anyone who suspects or knows that they have been abused sexually by someone employed by the Catholic Church:

If you suffered abuse, it was not your fault. If you are a victim of sexual abuse by deacon, or individual representing the Catholic Church, there are several things you can do:

•         Contact the appropriate law enforcement agency, which can help determine options for making a criminal complaint.

•         Contact a local child protection agency, a private attorney, a support group, an abuse hotline, or a mental health professional.

•         Contact a diocesan or eparchial victim assistance coordinator who is available to help victims/survivors make a formal complaint of abuse to the diocese or eparchy. The Victim Assistance Coordinator is also available to arrange a personal meeting with the bishop or his representative and to obtain support for the needs of the individual and families. IV

In 2004 Annual Report which details the degree of implementation undertaken by each diocese was published with this forward by Bishop William S. Skylstad, President, United States Conference of Catholic Bishops:

The last three years have been a humbling experience for the Church. We bishops have had to face the sinful betrayal of trust by those who should have been most trustworthy. We have had to deal with the continuing consequences of these betrayals. We have pledged to hold ourselves accountable, as far as is humanly possible, to see to it that this betrayal never happens again.

The annual report is described in these terms:

This second annual Report on the Implementation of the "Charter for the Protection of Children and Young People" is the result of the commitments made by the Catholic bishops of the United States when we adopted the Charter in June 2002. One of these commitments was to be publicly accountable for fulfilling the actions outlined in the Charter to help heal those wounded as young people by sexual abuse by clergy and to prevent such abuse in the future.

This public accountability was insured by hiring independent auditors who produced the report. The closing words aptly capture the hope for the future:

My brother bishops and I pray that what we have done in the last three years will bring about a restoration of trust. In particular, I hope that all who have suffered abuse by clergy or any representative of the Church will now be willing to share what happened to them so that both they and we may be healed. No one who has not experienced such a trauma can fully appreciate its shattering effects. Yet through knowledge of what others have suffered, we can have greater sensitivity to their pain and be better able to help, (www)

Needless to say, the creation and implementation of the Charter in 2002 did not mean that all bishops were attuned to shedding their former dysfunctional ways. Some bishops continue to badmouth Catholics who bring lawsuits against them. Still others drag their feet and try to invent ways to circumvent court orders to turn over documentation relative to particular cases. Overall, however, most bishops turned around their entire approach to the issue.

Sometimes deep pain and failure are a stimulus to reflective, to conversion, and to renewed forms of action. Sad to say, most dysfunctional aspects of the Vatican's system of tribunals are unexamined and unchanged. Bishops continue to be chosen making use of secret consultations that have the effect of appointing candidates that favor Vatican policies; accountability of bishops to their clergy and to locally generated pastoral plans remains weak. Sacramental confession of sins continues to be so privatized, sanitized, and gutless that little or no remedy for the social effects of sin is forthcoming. Yet, this is the church we love—both flawed and faithful, good and evil, misguided and inspired.

Two Closing Footnotes

My reflections must come to a close. Before doing so, however, I want to make a make two brief reflections: one relative to gay seminarians, that other relative to humility in the papal office.

Members of the hierarchy have championed a whole assortment of "false leads" when it comes to analyzing and healing the current crisis. Some claim that the pedophilia is "the work of the devil." Others claim that it all goes back to the "reluctant celibacy that was imposed" on those who had authentic priestly vocations. Still others say that the problem resides with "the gay culture" that has thrived within our seminaries and within our rectories. The later analysis caught on, sad to say, and gained a sizeable hearing within the hierarchy. Gay Catholic bishops, meanwhile were cowered into silence by a whole assortment of misguided myths and moral teachings that go back centuries. There is neither the time nor the space to sort this out here. I can only offer a small corrective-a public letter that the Episcopal Bishop Gene Robertson offered to Pope Benedict:

I believe it is misguided and wrong for gay men to be scapegoated in this scandal. As a gay man, I know the pain and the verbal and physical violence that can come from the thoroughly debunked myth connecting homosexuality and the abuse of children. In the media, representatives of and advocates for the Roman Catholic Church have laid blame for sexual abuse at the feet of gay priests. These people know, or should know, that every reputable scientific study shows that homosexuals are no more or less likely to be child abusers than heterosexuals. Psychologically healthy homosexual men are no more drawn to little boys than psychologically healthy heterosexual men are drawn to little girls.

Sexual activity with children or teenagers is child abuse, pure and simple. Meaningful consent is impossible, by definition, for the underaged. You will not rid your church of sexual abuse by throwing homosexuals out of your seminaries or out of the priesthood. Homosexual priests have faithfully and responsibly served God throughout Catholic history. To scapegoat them and deprive them of their pulpits is a tragedy for the people they serve and for the church. Yours is a problem of abuse, not sexual orientation/

In my above reflections, I have refrained from offering any reflections on the role of the last two popes regarding the issue of sexual abuse of children by priests. This issue is very long and complex and would need thirty pages or an entire book to do it justice. I can only say, as a footnote, that the credibility of the Catholic Church does not rest upon maintaining that the current pope has a theological acumen, a pastoral sensitivity, and a judgment of character that is second to none. Rather, the credibility of the Bishop of Rome rests upon his ability to rely upon those who exceed him in every one of these traits and to humbly acknowledge his own bad judgment relative to pastoral cases he poorly handled in the past. It scares me to hear so many members of the hierarchy coming forward and excusing Benedict XVI from all wrong doing in every circumstance going all the way back to the Hitler years. Benedict XVI can demonstrate for the bishops of the world how to meet and hear the pain of the suffering and angry victims of abuse. He can demonstrate how to align himself with the victims and to threaten perpetrators with a policy of "zero tolerance." Yet, he cannot demonstrate to the bishops of the world how they can govern with confidence while exhibiting a transparency relative to their own shortcomings and their learning from their own failings. Yet, in my mind,

this is where the current policy of the U.S. bishops is potentially doomed to a short-term success followed by a long-term failure.

What stays in my mind is the instance where John Paul II was being interviewed relative to the period when he lived and worked in Krakow during the Nazi occupation. The myth-makers had already told and retold stories of how, at a moment's notice, he championed a Jewish boy by talking about "his catechism class" when the boy was being threatened with arrest as a Jew. When asked about this and similar feats of daring, John Paul II grew strangely silent. Finally, he said, with deep sadness in his eyes, "I did nothing!" At that moment, I understood his relentless campaign to meet with Jews, to hear their pain, to pray in their synagogues, to call them "our elder brothers." His very ability to take on this tireless role within the Church which inspired bishops everywhere was due, in some divinely inscrutably way, to his earlier weakness in doing "nothing." From that day forward, John Paul II stood considerably taller in my estimation. I was proud to have a leader of his stature.

I     David Manes, ''Vatican releases Church response procedure for sex abuse cases/' Jurist: Legal News and Research, 12 April 2010, http://jurist.org/paperchase/2010/04/vatican-releases-church-response.php

II    These familiar forms of juridical trials were slowly taken over by secular tribunals and thus, even in entirely secular courts today, jurors are chosen from within the community, witnesses swear an oath upon the bible to tell the truth, and the accused (or those lawyers acting in his/her name) are permitted to cross-examine witnesses. Above all things, courtroom procedures are generally open to public scrutiny.

ni Thomas Doyle, O.P., J.C.D., "THE 1922 & 1962 INSTRUCTIONS--CR//WE/V SOLICITATIONIS PROMULGATED BY THE VATICAN/' Documents ^Controversy, 04 March 2010, http://www.richardsipe.com/Docs_and_Controversy/ 2010-03-04-solicitation.html

lv U.S. Catholic Conference of Bishops, "Victim Assistance/' http://www.usccb.org/ocyp/victim_assistance.shtml

v Bishop V. Gene Robinson, "Amid abuse scandal, advice from Episcopal Bishop Gene Robinson to Pope Benedict," The Washington Post, 02 May 2010, http://www.washingtonpost.com/wp-dyn/content/ article/2010/04/30/AR2010043001102.html